Looking to Pharmacy’s Future in Accountable Care Organizations

The final rule that will guide the establishment of the much-anticipated Accountable Care Organizations (ACOs) was recently released and it includes several pro-patient, pro-pharmacy changes sought by NCPA to help ensure pharmacists are properly utilized.

The Centers for Medicare & Medicaid Services (CMS) took its share of lumps after proposing the initial ACO rule. Many of the entities considered most likely to establish ACOs were among the most critical of the rule. So it’s worth acknowledging some of the improvements CMS made between that proposed rule and the final version.

NCPA has argued that ACOs can improve health outcomes and ultimately reduce costs through more coordinated care, provided they are structured properly and incorporate community pharmacists. On behalf of those pharmacists, we provided comments to CMS that included specific recommended changes to achieve that goal. Fortunately, CMS accepted NCPA’s top recommendations.

First, the final ACO explicitly states that pharmacists are potential ACO participants and that ACOs must allow participating pharmacists to have a role in the ACO governance.

Second, CMS is letting individual ACOs know upfront which beneficiaries are assigned to that ACO and which are not assigned to that ACO. This fact takes care of many of the concerns NCPA voiced in our comment letter. For instance, that allows pharmacies and other ACO participants to better target their resources by knowing which beneficiaries are included. In addition, it helps protect pharmacies from any inadvertent HIPAA privacy violations that could have been triggered under the initial proposed rule.

Some other changes were also substantive. To facilitate potential ACOs with limited capital, such as in rural areas served by many independent community pharmacies, an advance payment program may pay some dividends. There is more flexibility for ACOs in setting up governing structures and in determining which beneficiaries get assigned to which ACO.

CMS will start accepting ACO applications on January 1, 2012, with enrollment start dates of April 1 and July 1. NCPA will continue to monitor and try to help shape the ACO process in a way that’s positive for patients and pharmacists alike.